Cryptocurrency Exchange KYC&AML Policy

IMPERIAL.EXCHANGE POLICY ON ANTI‑MONEY LAUNDERING, KNOW YOUR CUSTOMER AND TRANSACTIONS.

1. General provisions

Imperial.exchange adheres to international AML/CFT standards (FATF), BestChange recommendations and best practices in the digital assets market.

This Policy defines measures to prevent money laundering, terrorist financing and other illegal activities when using the service.

The objectives of the Policy:

- Preventing the use of the service for AML/CTF violations;

- Protecting clients from receiving assets with an increased level of risk;

- Complying with BestChange rules and the requirements of partners and platforms.

2. Risk‑based approach

Imperial.exchange uses a risk‑based approach (Risk‑Based Approach), under which the intensity of the review depends on the risk level of the client, the transaction, and the jurisdiction.

The risk assessment is carried out automatically and, if necessary, is supplemented by a manual review by a compliance specialist.

3. Risk-Score model and threshold values

To evaluate a transaction, the Risk-Score model is used, based on data from professional AML analyzers.

Threshold values:

- Low Risk: 0–49% — the transaction is executed automatically;

- Medium Risk: 50–69% — the transaction is suspended and sent for manual review;

- High Risk: ≥70% — the transaction is blocked until KYC/SoF procedures are completed.

The assessment factors include the source of funds, the history of the address/cluster, the type of entity (exchange/wallet/mixer), geographical risks, and behavioral indicators.

4. AML analyzers used

To analyze and make decisions, Imperial.exchange uses one or more valid AML analyzers:

- Crystal Blockchain;

- Chainalysis;

- AMLBot;

- CoinKYT

The analysis results are used to calculate the Risk-Score and determine whether KYC/SoF is required, whether the transaction should be suspended, or whether service should be denied.

5. KYC / SoF (identification and source of funds)

Imperial.exchange has the right to initiate customer identification (KYC) and source of funds (SoF) verification procedures when high‑risk conditions are met.

Reasons for verification:

- Risk-Score ≥ 50%;

- Signs of suspicious activity (structuring, circumventing restrictions, inconsistent behavior);

- Request from regulators or partners, or the need to protect the client and the service.

Possible list of requested materials:

- Passport or other identity document;

- Selfie with the document or photo requested by the support team;

- Confirmation of the source of funds (screenshots of the exchange/wallet, transaction history, P2P correspondence if necessary);

- Confirmation of ownership of the address (if necessary).

6. Stages and timeframes of the verification:

- Initial analysis — up to 24 hours;

- KYC/SoF verification — usually 1–3 business days;

- In‑depth verification — up to 7 business days (in complex cases or when documents are pending).

The timeframe may be extended if additional information is required.

7. Conditions for blocking and refunding funds

If the risk level is high, the transaction may be suspended or blocked until the verification is completed.

Refunding of funds:

- If Low/Medium Risk is confirmed, the exchange is carried out;

- For Medium Risk, if the risk is not confirmed or no documents are provided, a refund is possible minus the network fee;

- For High Risk or if there are signs of sanctions, a refund is possible only to the original address and in the absence of legal prohibitions.

Imperial.exchange has the right to refuse a refund if the refund would violate sanctions restrictions or legal requirements.

- a refund is only possible after successful KYC verification;

- the fee is up to 5% of the refund amount, but not more than $100;

- a refund is available only if there are no signs of illegal activity.

- In case of refusal to complete KYC, no refunds will be issued;

- In the event of confirmed unlawful activity, a refund is not guaranteed.

8. “Cleanliness” of incoming and outgoing transactions

Imperial.exchange ensures the quality and legitimacy of assets transferred to clients, regardless of the direction of the exchange.

Measures in place:

- Use of marked and clustered service addresses;

- Operation through verified and licensed platforms (where applicable);

- Issuance of unique one‑time addresses for each request, followed by consolidation of funds in the service’s wallets.

9. Preliminary AML check

The website offers the option of a preliminary paid AML check of an address or transaction.

A redirect to the official BestChange AML check service is allowed:

BestChange Report

10. The user has the right to:

- Share the results of the check with the Imperial.exchange operator to assess the exchange risks;

- Or refuse to share the results and confirm acceptance of possible risks (checkbox/confirmation on the website).

11. If the user has successfully completed the KYC/SoF procedure and the legality of his funds has been confirmed, any exchange or refund fee will be limited solely to the actual network fee. There are no additional deductions from the service in such cases.

12. Processing and storage of personal data

Imperial.exchange provides secure collection and storage of users' personal data.

The data is processed to the minimum extent necessary and is protected by technical and organizational measures.

The retention period for personal data and materials related to AML/KYC checks is at least 5 years, unless a different period is established by applicable legislation.

13. Refusal to provide services

Imperial.exchange reserves the right to refuse service or restrict transactions if an unacceptable level of risk is identified, if the client refuses to provide documents as part of KYC/SoF,

if there are signs of sanctions, or if there are attempts to circumvent the established procedures.

In some cases, the service may suspend the execution of an application until the internal review is completed and the necessary clarifications are obtained.

14. AML / Compliance Contacts

For all questions related to AML, KYC, and checks:

Email: imperialexchange@proton.me

15. Final Provisions

Imperial.exchange reserves the right to update this Policy as the requirements of regulators, partners, and the identification of new risks change.

The current version of the Policy is published on the service’s official website.